About SDS

OSHA includes Definitions in Section c of the Hazard Communication(Section c). "Safety data sheet (SDS)" means written or printed material concerning a hazardous chemical that is prepared in accordance with paragraph (g) of this section (i.e., Section c). Paragraph g describes content that must be included. Refer to http://www.osha.gov/dsg/hazcom/HCSFinalRegTxt.html for more details.

If you are an employer, you are required to make Safety Data Sheets available to your employees in accordance with OSHA's Hazard Communication Standard. If you are an employee who works with hazardous chemicals in the workplace, your employer is required to establish a Hazard Communication Program and train you about those chemicals.

RTK stands for Right-to-Know, and many people use the term Employee Right-to-Know Law in place of the Hazard Communication Standard. The wording comes from OSHA, who describes the purpose of the standard being based on employees having the "right-to-know" the hazards and identities of the chemicals they may be exposed to in their work environment.

Unlike the MSDS they replace, all SDS must have the same 16 section format. In addition, content of each section will be more standardized. You may still see some variation in organization of information within sections and some manufacturers or importers may elect to include additional information while others do not.

Employee Access to SDS

Yes, electronic systems are permissible as long as there are no barriers to an employee having access. For instance, if your electronic system requires the use of a computer, the employee must have access to a computer as well as any usernames or passwords necessary to access the computer or sds system.

There can be no barriers to access. This was a requirement of the previous standard and remains a requirement of the updated standard. Employees should be trained on how to access the information and to understand what they are reading. OSHA has refrained from putting an exact timeframe on how long it may take an employee to obtain the information.

Managing SDS

The manufacturer or supplier of products you buy is responsible for sending you an SDS with your initial product shipment, updating SDS as required, and sending you updated SDS with the first shipment after a significant change has been made to the SDS. Employers must ensure SDS for applicable products have been received and filed in a manner allowing immediate access to employees. Employers should include procedures in their written Hazard Communication Program explaining how they handle the receipt of SDS’s to ensure that the most current versions received are available to their employees.

No, some products are exempt from the HCS. Only hazardous chemicals used in the workplace are covered. Paragraph (b)(6) of the standard (http://www.osha.gov/dsg/hazcom/HCSFinalRegTxt.html) defines exempt products. They include things like food and cosmetics intended for employee consumption in the workplace, drugs sold in final packaged form (e.g., tablets or capsules) for delivery to a patient, tobacco or tobacco products, and consumer products for which the employer can show that use in the workplace is for the purpose intended by the chemical manufacturer or importer of the product, and that use results in a duration and frequency of exposure which is not greater than the range of exposures that could reasonably be experienced by consumers when used for the purpose intended.

You only have to keep SDS for hazardous products. However, many employers keep SDS, even for non-hazardous materials, since it is sometimes easier to keep such documents than to maintain a list of products not requiring an SDS or repeatedly explain why an SDS is not required for certain products.